Letters and Comments
API Letter on 2023 WBCSD Guidance on Avoided Emissions
Tuesday, October 29, 2024
API sent a letter to the World Business Council for Sustainable Development to provide a lubricants industry perspective on the 2023 WBCSD Guidance on Avoided Emissions, including concerns regarding lost opportunities for efficiency improvements and innovation for main market technologies.
API Comments on California's Request for a Waiver for ACF
Tuesday, September 17, 2024
API submitted comments to the U.S. Environmental Protection Agency on the State of California’s request for a Clean Air Act waiver for the Advanced Clean Fleets Regulation.
API Comments on California's Request for a Waiver for ACC II
Tuesday, February 27, 2024
API submitted comments to the U.S. Environmental Protection Agency on the State of California’s request for a Clean Air Act waiver for the ACC II light- and medium-duty vehicle standards.
Joint Industry Letter on Proposed NAAQS PM2.5 Revisions
Wednesday, November 1, 2023
API joined with over 70 other trade groups representing diverse businesses across the economy in urging the Biden administration to maintain the existing National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5).
API Comments on NHTSA's Proposed CAFE Standards
Monday, October 16, 2023
API submitted comments to the National Highway Traffic Safety Administration (NHTSA) on its proposed Corporate Average Fuel Economy (CAFE) standards for passenger cars and light trucks for model years 2027–2032 and fuel efficiency standards for heavy-duty pickup trucks and vans for model years 2030–2035.
API Comments on EPA’s Proposed Subpart W GHG Reporting Rule
Monday, October 2, 2023
API joined with the American Exploration & Production Council, Independent Petroleum Association of America, Petroleum Alliance of Oklahoma, and American Fuel and Petrochemical Manufacturers in submitting comments to the U.S. Environmental Protection Agency (EPA) regarding its proposed “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems.”
API Comments on CEQ’s NEPA Phase II Proposal
Friday, September 29, 2023
API filed comments urging the White House Council on Environmental Quality (CEQ) to reconsider its National Environmental Policy Act (NEPA) Phase II proposal to provide greater regulatory certainty and ensure NEPA follows its Congressional mandate.
API Letter to EPA Administrator Regan on EPA Methane Rule
Wednesday, September 20, 2023
Letter from API President and CEO Mike Sommers to U.S. Environmental Protection Agency (EPA) Administrator Michael Regan urging EPA to adopt a timeline for the final methane rule that accounts for the reality of supply chain delays for critical equipment.
API Supplemental Materials on EPA New Source Performance Standards (NSPS) OOOOb and Emissions Guidelines (EG) OOOOc
Wednesday, September 20, 2023
API conducted supplemental analysis on the impacts of EPA’s supplemental proposed “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review”.
API Comments on EPA's Proposed Regulation of GHG Emissions from U.S. Power Plants
Wednesday, August 9, 2023
API submitted comments to the U.S. Environmental Protection Agency (EPA) on its proposed regulation of greenhouse gas (GHG) emissions from U.S. power plants.